Office of Policy, Program Development and Evaluation
Meat and Poultry Advisory Committee Staff
INFORMATIONAL MEMORANDUM FOR THE SECRETARY
This memorandum provides a summary of activities and recommendations to the Secretary of Agriculture from this Committee’s May 5-6, 1999 meeting.
Congress established the National Advisory Committee on Meat and Poultry Inspection in 1971 under authority of the Federal meat and poultry acts. Both laws direct the Secretary of Agriculture to consult with an advisory committee before issuing product standards and labeling changes or on matters affecting Federal and State program activities. Membership in the Committee has been broadened to provide a greater representation of State and consumer interests for a better balance of constituent interests than in previous years. The Committee serves as a forum for sharing of ideas and insight about how our regulatory system can best serve both consumers and industry. The public is invited to participate in this process by making comments and suggestions, either at Committee meetings or in writing. The Committee provides feedback to the Agency on programs, budgets, and policies across a wide variety of issues. Mr. Billy, Administrator, Food Safety and Inspection Service (FSIS) chairs the Committee. Dr. Catherine Woteki, Under Secretary of Agriculture for Food Safety also participates in the oversight of the Committee and addresses the Committee on numerous issues.
The meeting was largely devoted to the following five policy issues:
Subcommittees considered these issues and reported their concerns and recommendations to the whole Committee. The public also attended the meeting and made comments and suggestions on the Committee’s proceedings.
ACTIVITIES AND RECOMMENDATIONS:
QUALIFICATIONS OF GOVERNMENT AND INDUSTRY PERSONNEL WHO CONDUCT HACCP TASKS
The Committee considered the qualifications of the Food Safety and Inspection Service’ (FSIS) Workforce of the future, in particular which disciplines and academic backgrounds would be most beneficial when considering applicants for the Consumer Safety Officer position.
As a result of its discussions, the Committee recommends that all of the disciplines (except engineering and computer science/programming) shown in the OPM qualification standards provide education in the scientific thinking relevant to the work of the Agency. In addition, the Committee recommends that the following academic backgrounds should also be considered: Anatomy, Biological and Agricultural Engineering, Food Science, Animal Science, Sanitary Science, Public Health, and Poultry Science. The Committee also recommends that basic knowledge of Statistical Process Control (SPC) and Microbiology are essential and relevant to the work of the Agency. In addition, training or coursework in SPC and Microbiology may be acquired before or after placement on the job.
Further, the Committee strongly believes that interpersonal relation skills are essential and that the Agency should determine that internal/external applicants possess these skills through interviews or other appropriate means.
USING CAMPYLOBACTER AS A PERFORMANCE STANDARD
The Committee supports the public health goal of reducing foodborne illnesses caused by Campylobacter. The Committee reached the conclusion that FSIS data is incomplete to determine if the prevalence of Campylobacter has any value to establish a performance standard. The Committee felt a risk assessment is needed in the planning stages that evaluates sources along the farm-to-table continuum, and determine where intervention would be effective and what would be considered an infectious dose. The Committee also noted that the Salmonella performance standard was established prior to a risk assessment.
The Committee supports the Agency’s direction to evaluate a Campylobacter performance standard that includes methodology, a baseline study, and a risk assessment. To formulate a specific recommendation on this issue, the Committee requested the National Advisory Committee on the Microbiological Criteria for Foods (NACMCF) to evaluate the options for defining a Campylobacter performance standard (e.g. quantitative vs. qualitative) and alternatives to a Campylobacter performance standard that accomplish the same public health objective. The NACMCF will discuss this request during its May meeting.
MANDATORY INSPECTION OF ALL ANIMAL FLESH FOODS
The Committee reviewed a concept paper presented by the Agency on this issue. After discussion, the Committee recommends the following broad guidelines for resolving the issue of what animals should be involved in mandatory inspection. The Agency should require mandatory inspection of any commercially slaughtered and or/processed birds or mammals for human consumption unless exempted. The Agency should also continue custom exemptions for mammals and create an equivalent exemption for birds. In addition, all inspection standards should be risk-based and appropriate for these amenable species.
The Committee also recommends that any change should be consistent with the USDA vision of a risk-based seamless federal /state inspection system. The Committee recommends these changes be made as amendments to the Poultry Processing Inspection Act and the Federal Meat Inspection Act and that Agency regulations should be changed accordingly.
As a follow-up action, the Committee recommends FSIS develop a revised concept paper incorporating these recommendations. In addition, the Committee recommends FSIS give priority to initiating discussions with the Food and Drug Administration on approving the use of nitrites in all amenable and non-amenable species.
ELIMINATING ALL EXEMPTIONS FROM FEDERAL INSPECTION
From its inception almost one hundred years ago, the meat inspection system has included a number of exemptions to generate political support for the legislation. Those exemptions were also incorporated into the poultry inspection program. Exemptions have proved unusually hardy, and remain in place today despite the fact that some may create risks to human health. The Committee believes exemptions should be addressed within the context of the new Pathogen Reduction/HACCP system.
The Committee urges the Agency to address exemptions that create a public health risk. Therefore the Committee recommends that FSIS undertake an assessment of the health risks associated with exemptions, develop and seek legal authority to implement performance standards and assign inspection resources where risk is highest and in a manner that assures compliance. The Committee assumes that a risk assessment will result in a determination that the processing of raw products, regardless of where that takes place, would be of highest risk and would be addressed first.
CONCEPTUAL FRAMEWORK FOR RISK FREE MEAT, POULTRY, AND EGG PRODUCTS
The Committee commends the Agency for taking this approach to address its mission and supports the assessment of what would be necessary to achieve complete food safety. The Committee agrees with the Agency that the best way to envision the system we all desire is to begin with a statement of the most desirable goal and the steps needed to achieve it. The Committee also recognizes that, as the Agency’s Strategic Plan and annual goals are developed, the state of technology, law, and budget will have an impact on these efforts.
The Committee completed its work on all five issues making several recommendations to the Agency and the Secretary of Agriculture. The Agency will add new issues to the Committee’s agenda from the enclosed list. The overall focus of the Committee is how best to advise the Secretary to foster participation by the parties affected by HACCP implementation. The Committee plans to meet in November 1999 to continue its discussion and prepare recommendations to the Secretary shortly thereafter.
National Advisory Committee on Meat and
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